Peninsular and Oriental Steam Navigation Company v The Commissioners for HM Revenue and Customs: [2015] UKUT 0312 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Proudman and Judge Bishopp on 19 June 2015.

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
1 December 2016
Category:
Tax
Release date:
19 June 2015

Read the full decision in .

CORPORATION TAX 鈥� double taxation relief 鈥� dividend paid to related company 鈥� share subscription by overseas company in UK subsidiary 鈥� shares almost immediately cancelled with reduction of capital 鈥� subscription money credited to reserves 鈥� reserves then paid by way of dividend to overseas company 鈥� no UK tax borne by reserves 鈥� onward dividend paid to UK holding company 鈥� liability for Case V tax 鈥� whether ICTA s 801(4B) to be applied to 鈥渦nderlying tax鈥� 鈥� no 鈥� appeal dismissed.

Updates to this page

Published 1 December 2016